Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Valuation - The royalty charges paid in respect of technical knowhow would be includible in the cost, irrespective of the fact that the same are paid at the time of sale. The measure of the royalty on the basis of sale price is just a convenient mechanism to measure the royalty payable on account of transfer of technical knowhow. - AT
Valuation - The royalty charges paid in respect of technical knowhow would be includible in the cost, irrespective of the fact that the same are paid at the time of sale. The measure of the royalty on the basis of sale price is just a convenient mechanism to measure the royalty payable on account of transfer of technical knowhow. - AT
Note: It is a system-generated summary and is for quick reference only.
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